MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $2,765 for the taxable year 1996. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
The issues for decision are: (1) Whether petitioners' jade activity was an activity engaged in for profit within the meaning of section 183, and (2) if so, whether petitioners...
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